Public Disclosure Authorized

The World Bank

Nachtigal Hydropower Project (P157734)
Public Disclosure Authorized

Project Information Document/

Integrated Safeguards Data Sheet (PID/ISDS)
Public Disclosure Authorized

Appraisal Stage | Date Prepared/Updated: Jan 18, 2018 | Report No: 125610
Public Disclosure Authorized

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Nachtigal Hydropower Project (P157734)

BASIC INFORMATION

A. Basic Project Data OPS TABLE

Country Project ID Parent Project ID (if any) Project Name

Cameroon P157734 Nachtigal Hydropower
Project
Region Estimated Appraisal Date Estimated Board Date Practice Area (Lead)
Africa April 9, 2018 May 31, 2018 Energy and Extractives

Financing Instrument Borrower(s) Implementing Agency

IBRD Guarantee Government Republic of Nachtigal Hydropower
Cameroon Project Company (NHPC) and
Electricity Development
Corporation (EDC)

Proposed Development Objective(s)

The project development objective is to increase the availability of renewable energy power and leverage private
finance for the Nachtigal Hydropower Project.

Indicative Financing (in USD Million)

Shareholder Equity 336
Debt from Development Finance Institutions 867

Commercial debt from local private banks 197

Total 1,400
Estimated Payment Guarantee 100
Estimated Local Loan Guarantee 200
Estimated Total Guarantee Provided 300

Environmental Assessment Category Concept Review Decision

A January 13, 2016

SAFEGUARDS_TABLE_OPS
Have the Safeguards oversight and clearance functions been transferred to the Practice Manager? (Will not be disclosed)
No

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Other Decision (as needed)

B. Introduction and Context

Country Context

1. Cameroon has vast natural resources, including oil, gas, minerals, agricultural land, and forests with remarkable
biodiversity, which provide a strong basis for development. It is a medium-sized (475,650 km2) country in Central Africa
with a population of about 24 million in 2016, which is growing at around 2.5 percent per annum. Strategically located at
the heart of the Gulf of Guinea, Cameroon is at once the gateway to the economy of a part of Central Africa and a trade
route between the economies of West and Central Africa. Its gross national income per capita stood at US$1,357 in
2016, making it a lower-middle income country.

2. Cameroon remains characterized by high levels of poverty and weak social indicators. Poverty declined only
marginally since 2001, from 40.2 percent to 37.5 percent in 2014 and is increasingly concentrated in Cameroon’s
northern regions, where it worsened in the same period. The country ranked 153 out of 187 on the 2015 Human
Development Index with some indicators, including life expectancy, declining over the last 10 years, and infant and
maternal mortality rates still exceedingly high. Moreover, outbreaks of violence in Cameroon’s North and Far North
Regions and a secessionist movement in country’s English-speaking areas are inhibiting economic activity, and increased
security spending is straining the public finances.

3. Economic growth has been inconsistent and has slowed down recently. Economic growth averaged 3.3 percent
per annum in the 2000s, but the 2009 global financial crisis led to a slump due to weaker demand for Cameroon’s non-oil
exports. Whilst economic growth picked up in 2014-15 with a growth rate of 6 percent, the economy slowed down in
2016, when growth was estimated at 4.5 percent and again in 2017, when it reached 3.7 percent. A decline in oil
production, lower international commodity prices and the contraction in rubber and coffee production have reduced
growth whilst improved energy supply, continued implementation of three-year emergency plan (PLANUT), and
increased public works related to the preparation of the 2019 African football cup have acted as a support to GDP
growth.

4. Cameroon’s sovereign debt situation has deteriorated recently due to the funding of major infrastructure
projects concomitant with lower oil revenues. High levels of public investment have substantially increased the share of
non-concessional debt, and debt-service payments are intensifying fiscal pressures. Public debt levels rose sharply from
21.5 percent in 2014 to 33.7 percent at end-2017, and a recent World Bank-IMF assessment concluded that Cameroon is
at high risk of debt distress.

Sectoral and Institutional Context

5. In line with the GESP, the 2014 Least Cost Power Sector Expansion Development Plan (Plan de Développement
du Secteur de l’Electricité, PDSE), forecasts peak demand to quadruple by 2035, with a range from 3,900 MW to 5,500
MW depending on the growth scenario1 (median or high). Electricity consumption is expected to range from 24,400
GWh (median) to 33,400 GWh (high). In order to deliver on the Growth and Employment Strategy Paper (GESP) goals,
Cameroon will, in parallel, need to significantly increase access to electricity for its population. The current access rate to

1 The high scenario is based on GDP growth rates of 6.5% annually and aggressive industrial expansion. The median scenario is based on GDP
growth rates of 6.0% annually and a more conservative path for industrial expansion.

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electricity is 50 percent – though this rate is much lower in rural areas. Cameroon’s recently approved Rural
Electrification Master Plan intends to increase to 88 percent the population living in electrified localities by 2022 (from
74 percent in 2016). This would be achieved through a mix of grid extension (80 percent) and off-grid solutions (20
percent). Both large grid-connected hydro and mini-hydro for off-grid schemes would be required to address the needs.

6. The Government of Cameroon (GoC) intends to focus hydropower development on the Sanaga River, where
half of this potential is concentrated, rather than spreading it across multiple river basins. The Proposed Nachtigal
Project, with its compact layout, limited environmental and social impacts and reasonable overall cost per MW installed,
stands out as the next project to be developed on the Sanaga River.

7. This development program of the energy sector is strongly rooted in a series of reforms undertaken by the
Government for the last two decades. The sector has seen several reforms over the years, including important structural
changes. In order to strengthen the financial sustainability of the sector and to further lay the foundation for private
sector participation, the Government has initiated a second phase of reform. In 2010, the Cameroon power sector
suffered from a lack of investment in transmission and large technical and commercial losses which created a critical
bottleneck to the expansion of power generation capacity and of Cameroon’s hydroelectric resources of the Sanaga
River Basin. In response, the Government adopted the New Electricity Law in 2011, which included: (a) the transfer of
transmission network management from the Cameroonian Electrical Company (ENEO) to a new state-owned entity, the
National Electricity Transport Company (SONATREL), whose mandate includes the development, operation,
maintenance, and expansion of the national transmission grid, including its interconnection with neighboring countries;
(b) changes to water storage activities, including the transfer of the water storage concession of the Sanaga Basin
reservoirs to the Electricity Development Corporation (EDC)2, and, (c) the introduction of new penalty charges in the
event that ENEO fails to meet agreed performance targets

8. The Nachtigal Hydropower Project – which has among the lowest tariff (levelized tariff about 6.0 EURct/kWh)
for any generation project in Sub-Saharan Africa, will be a key part of the effort to reduce the costs of electricity in
Cameroon and to promote sector sustainability. The commissioning of new hydropower projects such as Nachtigal and
Memve’elé3 - which together will represent roughly 40 percent of Cameroon’s generation capacity – will, in addition to
adding significant clean energy generating capacity, continue the downward trajectory in production costs. The strategy
has already seen some level of success. The regulator has estimated the projected average annual compensation for
2018-2020 at US$12 million compared with US$37 million in 2017, following the commissioning of Memve’elé and
added hydropower generation following the commissioning of Lom Pangar.

9. The Proposed Nachtigal Hydropower Project builds on a sustained engagement in the energy sector by the
World Bank Group in Cameroon, to accompany the Government in the reform agenda. The World Bank Group has been
a long-term, strategic partner of Cameroon’s energy sector, with a strong portfolio of projects and consistent support to
the government’s reform agenda. It has built a close working relationship with all sector stakeholders and has become a
trusted partner in regard to policy, institutional development, and sector investment. Over the past few years, the
World Bank Group has financed the following activities: (i) the Energy Sector Development Project (P104456) which
provided assistance to update the sector framework and supported rural electrification; (ii) the Lom Pangar Hydropower
Project (P114077), which supports a regulating dam to reduce seasonal water variability in the Sanaga basin; (iii) the
Electricity Transmission and Reform Project (P152755), which will help improve the capacity, efficiency, and reliability of

2 The EDC was created in 2006. It holds public electricity sector assets and its mandate includes the development, management, and operation of
hydropower assets
3 Memve’elé is a 211 MW hydropower plant, publicly financed, commissioned in 2018.

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the national transmission network; and (iv) the Hydropower Development on the Sanaga River Technical Assistance
Project (P157733), which aims to support institutional capacity building and knowledge transfer to the GoC in refining its
tools and strategy to develop its hydropower resources.

10. The World Bank Group has been instrumental in securing private finance for this project, which is one of the
very few public-private partnerships (PPP) in hydropower in sub-Saharan Africa, and a good demonstration of the
principles of maximizing finance for development (MFD). The World Bank Group brings a unique set of experience, skills
and instruments to attract private sector financing for this project. Electricity of France (EDF) will be a major shareholder
in the project company; while a number of local commercial banks led by Standard Chartered and Société Générale will
provide debt. The work by the WBG – together with EDF – to deliver this project will build on a sustained sector
engagement by the World Bank Group and a track record of provision of appropriate risk mitigation and financing
instruments by the Bank, IFC and MIGA.

Relationship to CPF

11. The proposed project will support the strategic objectives of the GoC’s Vision 2035 to achieve shared growth,
reduce poverty, and create jobs through increased industrialization, improved productivity, and better governance.
Similarly, the project will contribute to the GoC’s GESP 2010-2019, which aims to increase non-oil growth by investing in
key infrastructure, improving productivity and the business climate, and strengthening human development and
regional integration. By supporting the GoC to increase low cost and environmentally friendly power generation, the
project will help establish a predictable environment for future growth and competitiveness of Cameroon’s economy,
which in turn will be essential for creating jobs and lifting marginalized and vulnerable populations out of poverty, which
is aligned with the Bank’s twin goals of reducing poverty and boosting shared prosperity.

12. The World Bank Group FY17-21 Cameroon Country Partnership Framework (CPF),4 approved on March 28, 2017,
translates the core constraints identified by the SCD into three areas of focus: (i) increasing rural productivity,
particularly in the north; (ii) improving the business environment for the formal and informal private sector; and (iii)
supporting improvements of governance in the private and public sector. This project will actively contribute to pillars
(ii) and (iii) of the CPF and to the governance and private sector support objectives of the GoC’s Vision 2035.

C. Proposed Development Objective(s)

13. The project development objective is to increase the availability of renewable energy power and leverage
private finance for the Nachtigal Hydropower Project.

14. The achievement of the PDO will be assessed using the following key PDO Level Outcome Indicators:

▪ Generation capacity of energy constructed under the project (MW) (Corporate Results Indicator);
▪ Additional operating capacity available (MW)
▪ Amount of private capital mobilized for the Nachtigal Hydropower Project (EUR million) of which from local
sources (FCFA million);
▪ Avoided global greenhouse (GHG) emissions (ton CO2).

4 Report No. 107896-CM.

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D. Concept Description

15. The Nachtigal Hydropower Project is a greenfield, 420 MW, run-of-river hydropower plant on the Sanaga River
located at Nachtigal falls, which is approximately 65 km north-east of Yaoundé. In 2013, a joint development agreement
was signed to develop this strategic project. During past four years, developers and GoC have significantly advanced the
Nachtigal Project with an objective to reach financial close in 2018. This Project is now developed by Nachtigal Hydro
Power Company (“NHPC” or “Project Company”), whose shareholders are the Republic of Cameroon, EDF International
(“EDFI”) and the IFC, pursuant to the Shareholders Agreement signed on July 7, 2016.

16. IBRD will provide two project-based guarantees - a payment guarantee and a loan guarantee - per the Bank
Directive on Investment Project Financing. IBRD guarantees will backstop certain GoC obligations in the Project
Agreements5 and provide comfort to the commercial banks involved. Specifically, the IBRD payment guarantee will
enhance GoC’s obligations under the State guarantee assuming certain liquidity security obligations in favor of the
Project Company and in relation to the Power Purchase Agreement (PPA). The IBRD loan guarantee will backstop certain
payment obligations of GoC towards lenders of the local financing tranche.

17. IFC is jointly developing the Project with Electricité de France (EDF) and investing InfraVenture funds to cover
development costs. IFC is considering providing both equity - 30 percent shareholding and senior debt in its role as the
leading debt provider. It is also the Mandated Lead Arranger to mobilize funding from other development finance
institutions (DFIs). IFC and other DFI investors will take comfort from the credit enhancement provided by the IBRD
under its Payment Guarantee on behalf of the GoC.

18. In addition, MIGA will provide equity insurance to EDF International (EDFI) for its equity and shareholder loans in
the amount of up to EUR 206 million for a tenor up to 15 years.

SAFEGUARDS

A. Project location and salient physical characteristics relevant to the safeguard analysis (if known)

19. Nachtigal Hydropower Project involves the development of a large scale 420 MW hydropower project, including
a 1,455-meter-long, 13.6-meter-high main dam in roller compacted concrete, creating a 421-ha upstream reservoir, a
concrete lined headrace channel about 3.3 km long and 14-meter-deep on average to conduct water to the
hydroelectric power plant, with a maximum flow rate of 980 m 3/s corresponding to the Project design flow. The
Nachtigal Project comprises a 225-kV substation and a double circuit 50.3-kilometer transmission line to evacuate the
power produced to the Nyom 2 connection substation. The Project will form part of a hydropower cascade that will have
cumulative impacts.

20. Nachtigal Hydropower Project is located in natural and modified habitats where terrestrial and aquatic
biodiversity values exist. The Project will have a footprint of 2,051 ha for the construction of its main components and
ancillary facilities. While only 5 households will be physically displaced, the Project will directly impact 917 farmers
through agricultural land expropriation and restrictions to land use, and approximately 117 fishermen, 83 fish traders,
and 960 sand miners will be temporarily or permanently economically displaced. During its peak construction period, the
Project will employ a workforce of nearly 1,500, with the attendant stress that such a population influx will have on the

5The Concession Agreement with the Project Company; the Commitment Agreement with the Project Company, ENEO and SONATREL; the
Connection and Dispatch Agreement with the Project Company and SONATREL; and the Government Support Agreement.

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cost of goods and services, public security and social cohesion. Although modest in size, the progressive filling of the
dam’s reservoir might generate population influx as recently experienced with the Lom Pangar Project, where thousands
of people have migrated from Chad, Nigeria, and all over Cameroon and settled near the reservoir and have rapidly built a
a fast-growing permanent human settlement in small cities, small but growing commercial fishing industry. This massive
influx resulted in a huge pressure on resources, and the basic infrastructure (lack of school, healthcare, water and
sanitation) that was originally designed for small villages. The Project will form part of a hydropower cascade that will
have cumulative impacts.

21. Given all these factors, the Nachtigal Hydropower Project has been designated as a Category A project because it
may cause adverse environmental and social impacts that may be significant and irreversible. A comprehensive ESMP has
been prepared, addressing environmental impacts, health and safety, labor influx, and organizational capacity. As part of
the ESMP, a full set of safeguard instruments has been prepared and consulted upon including the following management
plans: Biodiversity Action Plan, Migratory Influx Management Plan, Resettlement Action Plans, and a Livelihood
Restoration Action Plan (sand mining workers).

B. Borrower’s Institutional Capacity for Safeguard Policies

22. The Project company (NHPC) assessment has shown that NHPC has very strong capacity and has demonstrated
commitment to these issues during the preparation of the Project. As mentioned above, NHPC has prepared a
comprehensive ESMP, addressing environmental impacts, health and safety, labor influx, and organizational capacity.
NHPC’s environmental and social team is comprised of five qualified professionals who have been on site since 2014
playing an active role in the identification of the Project’s environmental and social risks and mitigation measures, and
ensuring the implementation of an effective stakeholder engagement strategy and grievance mechanism. The team,
with the support of qualified consultants, has also actively participated in the government-led census of land to be
expropriated to ensure that the resettlement action plans comply with IFC Performance Standards. NHPC’s
environmental and social team will remain on-site for the duration of construction, ensuring continuous engagement
with communities. NHPC will hire five additional professionals to ensure the implementation of the ESMP and the
complementary mitigation action plans (i.e., RAPs, livelihood restoration for sand miners, management plan of
migratory influx, cultural heritage action plan, biodiversity action plan). Adequate financial resources and equipment
have been allocated for the ES team and NHPC senior management has demonstrated its commitment for ES, including
through a strong support from EDF.

23. EDF will act as Owner’s Engineer to ensure that execution of works by the EPC contractors comply with
established cost, quality, delivery deadlines, as well as compliance with EHS contractual requirements. EDF will retain
one Safety Engineer (54 months), one Environmental Engineer (39 months), and one EHS inspector to monitor
contractors’ EHS performance. All EPC contractors will also appoint their own personnel for the implementation of their
integrated management plans

24. More broadly, Cameroon has stable environmental and social institutions, namely MINEPDED, the Ministry of
Domain, Cadastral and Land Registration Affairs, and Ministry of Socials Affairs, which are central ESIA authorities. The
country has also a comprehensive environmental and social legal framework, including the 1996 Environmental Law and
its implementation decrees. (De) centralization of ESIA entities are weak and have limited capacities. Any project for
which an environmental assessment is carried out, is subject to the administrative and technical supervision of the
competent authorities. This supervision focuses on the effective implementation of the ESMP included in the ESIA. The
Order No 0010/MINEP of April 3, 2013 requires a setup in each Division of the country, a Committee for the technical

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and administrative supervision of ESMP. However, only one Divisional committee has not been set up in the Project
area. In addition, permanent budget for external oversight of ESMP is not fully integrated into the Ministry’s planning
process. Regional ESMP Unit, divisional Environmental inspections, and Environmental Assessment unit and divisional
committees do not have adequate financial provision. They lack adequate equipment for fieldwork, and Senior staff lack
personal vehicles. A central ESIA database is lacking. To ensure a proper safeguards compliance monitoring, the Project
will contribute to set up different Divisional Committees in charge of monitoring ESMPs in the Project areas. The costs
associated with their operation (supervision and inspection missions) will be borne by the Project.

C. Environmental and Social Safeguards Specialists on the Team

Cyrille Ngouana, Sr. Environmental Specialist

Kristyna Bishop, Sr. Social Development Specialist
Alain Owono, Sr. Social Development Specialist

D. Policies that might apply

25. All the Performance Standards apply, although the relevant for this project are: PS1: Assessment and
Management of Environmental and Social Risks and Impacts; PS2: Labor and Working Conditions; PS3: Resource
Efficiency and Pollution Prevention; PS4: Community Health, Safety, and Security; PS5: Land Acquisition and Involuntary
Resettlement; and PS6: Biodiversity Conservation and Sustainable Natural Resources Management. PS8: Cultural
Heritage. PS7: Indigenous Peoples is not relevant as no indigenous peoples have been identified in the project’s area of
influence.

Performance Standards
PS 1: Assessment and Management of
Environmental and Social Risks and
Impacts
PS 2: Labor and Working Conditions
Apply?
Explanation (Optional)
(Yes/No/TBD)
The Project may have adverse and irreversible
environmental impacts, including: (i) the loss of
natural habitat due to flooding and infrastructure
footprint; (ii) predictable environmental, human, and
health risks associated with the construction and
operation of facilities; (iii) the risk of reducing the
viability of a distinct population of Leddermaniella and
Yes (iv) encroachment into the Mbam Minkom - Kala
Birdlife Important Bird Area (IBA/KBA). Prior to
commissioning (first turbine), the project has
committed to retain suitably qualified E&S
professionals (E&S team) and ensure that its E&S team
has the capacity to effectively manage the E&S risks
and impacts linked to the operation of the
hydropower plant.
NHPC has a current workforce of about 45 employees
and will have a total of about 180 employees during
the operation of the hydropower plant. The Project
Yes
has a five-year construction schedule and the
workforce will be approximately 1,500 at peak
construction. NHPC will then need to produce a

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Apply?
Performance Standards Explanation (Optional)
(Yes/No/TBD)
human resources policy and related procedures that
are in line with Lender standards. Policy and
procedures shall include, but not be limited to:
working hours, weekly rest, annual leave, workers’
health, the right to work, job security, nutrition,
discrimination against workers, housing allowance,
workers covered by social security, workers provided
with a copy of their contract, contractors’ system to
adequately record and compensate for overtime work,
workers’ wages in compliance with remunerations
established by applicable collective bargaining
agreements or official tariffs, no children below
minimum working age (15 years) engaged in any type
of work and no children between 15 and 18 years old
employed in hazardous work, etc. If non-compliances
are identified, NHPC will require contractors to take
immediate corrective actions.

Each contractor is expected to produce a site specific

Occupational, Health and Safety Plan and related
procedures that refer to identifying and minimizing
hazards to workers; providing appropriate equipment;
identifying preventive and protective measures;
training of workers; documenting and reporting
accidents, diseases, incidents, and near misses.

NHPC will produce plans and minimum standards for

the construction workers’ accommodation and the
Base de Vie for lender approval prior to construction.
Staff working for EPC contractors responsible for civil
works (LOT GC) and for the installation of electro-
mechanical equipment (LOT EM1) will be
accommodated in a workers’ accommodation with
capacity for 1,500 people that will form part of the
main construction base camp. NHPC will ensure that
EPC contractors make all workers aware of the
existence of a workers’ grievance mechanism required
by Cameroon national law and successfully used in
Lom Pangar.

During construction, mitigation measures at the

PS 3: Resource Efficiency and Pollution construction site will include standard construction
Yes
Prevention pollution prevention and control measures.

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Apply?
Performance Standards Explanation (Optional)
(Yes/No/TBD)
During operations, the risk of eutrophication of the
reservoir is considered low as the only industrial
effluents from a sugar refinery located upstream (1-2
m3/s) are minimal compared to the flow of the Sanaga
River (200 to 650 m3/s during the dry season with and
without water flow regulation from the Lom Pangar
dam, respectively). In addition, the maximum water
residence time in the reservoir (27.8 million m3) is
estimated to be 12 hours only. The main water quality
risk during operations is associated with a potential
future increase in the agricultural development of the
surrounding area. Nevertheless, NHPC will constantly
monitor the presence of water hyacinth in the
reservoir to prevent the spreading of this water pest.
To avoid contamination of the river downstream the
powerhouse, NHPC will install water oil separators to
remove any oil that might leak from the equipment.

The villages that will likely see a migrant labor influx

are Ndji (estimated population 849), Ndokoa
(population 273), Minkouma (population 122),
Olembe (population 637), Nalassi (population 642),
Emana-Batchenga (population 1,353), and Ballong I
(population 1,493). To limit the influx of migrants, the
EPC contractors have committed to hire about 20
percent of the required workforce locally, and
implement a work schedule that allows migrant
workers to regularly return home so that it dissuades
families of workers to move into the area. In addition,
to promote local employment, the civil works EPC
PS 4: Community Health, Safety, and contractor (LOT GC) will put in place shuttle buses to
Yes
Security daily transport workers from/to their homes up to 20
km from the work site. The GC EPC contractor has
developed a code of conduct and disciplinary
procedures that will be explained to workers of all EPC
contractors and sub-contractors at the time of
induction and will be posted in French and local
languages around the base camp. This code of conduct
will be endorsed by each worker. NHPC’s grievance
redress mechanism shall acquire the necessary
expertise to handle this type of complaint. To reduce
the impact on affected communities, NHPC will
implement a number of mitigation measures in
coordination with local authorities which are detailed

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Apply?
Performance Standards Explanation (Optional)
(Yes/No/TBD)
in the Migratory Influx Management Plan. NHPC will
also include gender specific mitigation measures
within its Migratory Influx Management Plan to ensure
negative impacts on women due to the project are
addressed.

Road safety. EPC contractors will be required to

include activities and/or service providers in road
safety programming which address the specific needs
of blind and partially sighted people.

Emergency preparedness and response. EPC

contractors are required to draft Emergency
Preparedness and Response Plans and these will be
submitted for NHPC approval and Lender review- prior
to site mobilization.

Community exposure to disease. The impounding

created by dams often results in an increase in water
related vector borne diseases such as malaria,
schistosomiasis, and filariasis (including
onchocerciasis). In addition, the in-migration of
workers may result in an increase in sexually
transmitted diseases and human immunodeficiency
virus (HIV), and an increase in accidents can also be
expected as result of the increase in vehicle traffic. As
part of NHPC’s Environmental and Social Management
Survey, health indicators will be defined and
monitored throughout the duration of the project.

Dam Safety. Nachtigal is considered a large dam as it

will include a 1,455-meter-long, 13.6-meter-high main
dam in roller compacted concrete. In March 2015, an
independent Panel of Experts performed a review of
the dam’s detailed feasibility study, which included
aspects of dam safety (i.e. stability, ability to
withstand a 100,000-year flood, and auscultation
system). Recommendations provided by the panel
were adopted by NHPC. In addition, the World Bank is
providing, through the IDA-financed Hydropower
Development on the Sanaga River Technical Assistance
Project, the financing of a Dam Safety Panel of Experts
to supervise the construction of Nachtigal HPP. The
dam safety measures shall be outlined in the project’s

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Apply?
Performance Standards Explanation (Optional)
(Yes/No/TBD)
dam safety emergency plan to be completed and
approved at least one year before the first
impoundment of the dam, and adequate resources
shall be budgeted for its implementation and
maintenance. As part of the dam’s operation and
maintenance plan, to be completed and approved at
least six months before the first impoundment of the
dam, NHPC shall also develop and implement a dam
safety surveillance program.

Security forces. Access to the construction basecamp

will be controlled through the use of cameras, badges
and a team of 30 unarmed private security guards
under the responsibility of the GC EPC contractor. In
addition, the Government of Cameroon (GoC) has
declared Nachtigal a project of national priority and
will station 51 military personnel on site to protect its
perimeter and sensitive areas. NHPC shall carry out a
security risk assessment to identify the likely security
threats during construction and operation that would
require a response by security personnel, and the
potential impact that such response might have on
community members. Based on the outcomes of the
security risk assessment, NHPC shall develop a security
management plan.

Gender Based Violence (GBV). The prevalence of GBV

in Cameroon is high and is a deeply rooted social
phenomenon. It is therefore impossible to fully
prevent GBV. However, the risk for GBV in the context
of the project, can and will be partially mitigated.
During project preparation, GBV risk was clearly
outlined in the Environmental and Social Review
Summary (ESRS, May 2017). Some fundamental
specifications have been incorporated in the contract
documents where for example, it is indicated that
NHPC will ensure that EPC contractors’ code of
conduct and disciplinary procedures include the
prohibition to engage in any type of sexual behavior
with minors and any type of abuse or violence against
women and girls. In addition, NHPC will implement a
communication campaign to explain what is the
expected behavior of workers in host communities
and how can a member of the community file a

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Apply?
Performance Standards Explanation (Optional)
(Yes/No/TBD)
related complaint at NHPC’s office located in
Batchenga. NHPC’s grievance redress mechanism will
acquire the necessary expertise to handle this type of
complaint.
The development of the project will entail the
temporary and permanent loss of land and fishing
grounds for populations in the dam impact area,
transmission line, and NHPC base camp in Batchenga.
Resettlement Action Plans (RAPs) have been prepared
for these three areas: (i) Dam: individual
compensation will be provided to 147 PAPs whose
agricultural plots amounting to 142 ha will be
expropriated (22 percent of the land is cultivated by
women); (ii) Transmission line: Individual
compensation will be provided to 565 PAPs whose 100
ha of agricultural plots will be affected; (iii) NHPC base
camp: 207 PAPs will be impacted by the loss of 19 ha
of agricultural land.
As of October 2017, 93 information and consultation
meetings with more than 2,300 participants (i.e. PAPs,
local authorities) have been organized by the NHPC
environmental and social team to explain and present
the results of the assets inventory and the eligibility
PS 5: Land Acquisition and Involuntary and compensation matrix. Expropriation and
Yes
Resettlement compensation decrees were signed in July 2017 for the
dam, and in February 2018 for the transmission line
and NHPC base camp. Compensation payments for the
dam area were finalized in December 2017 with only
compensation for 2 PAPs to be completed, and
transactions for the acquisition of replacement land
are expected to conclude in March 2018.
Compensation payments for the transmission line
right-of-way and NHPC’s base camp in Batchenga are
expected for the third quarter of 2018.
NHPC retained a local NGO who met with each
impacted household (both spouses present) to explain
the compensation payment amount and discuss best
options to use the money to ensure they restore their
income generating activities. Implementation of
livelihood restoration measures will be closely
monitored by NHPC environmental and social team
and socio-economic data will be collected annually by
the consulting firm that prepared the RAPs through
statistically sound sampling methodologies until the

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Performance Standards
PS 6: Biodiversity Conservation and
Sustainable Management of Living Natural
Resources
Apply?
Explanation (Optional)
(Yes/No/TBD)
third year after the filling of the reservoir.
The project is not located in any of Conservation
International’s Biodiversity Hotspot or High
Biodiversity Wilderness Area, or within an Endemic
Bird Area. There are no Protected Areas or
Internationally recognized areas for biodiversity within
or near the project area, either upstream or
downstream. The river is classified as Modified Habitat
due to the extreme changes in minimum flow rate
resulting from operation of the Lom Pangar regulation
reservoir upstream of the project. In addition to the
ESIA, NHPC conducted several complementary studies:
(i) an inventory of the flora and fauna was conducted
in 2014 to determine if endangered, endemic, or
migratory species are present in the Project area of
influence; and (ii) an ichthyologic study to identify fish
species composition and abundance was performed
from January to October 2014. Several Ecosystem
Services were identified within the project area,
including fishing, sand mining, traditional medicines,
wood collection, bushmeat hunting, and freshwater.
Studies identified two aquatic plants (Leddermaniella)
Yes
and nine fish species which triggered critical habitat.
To comply with the requirements of IFC PS6, a Project
Biodiversity Action Plan (BAP) was developed, and
specific mitigation measures to address these impacts
are described, including “net gain” for critical habitat.
NHPC is reviewing this BAP to strengthen the
mitigation of impacts by the transmission line. The
measures regarding bird collision/electrocution and
monitoring will be improved. To ensure compliance
with PS6, continued long-term commitment is
required to the collection of ecological and
hydrological (flow/water level) data at key locations
downstream of the dam during construction and
operation, and the subsequent refinement of the
Environmental Flow Release regime in response to
changes observed to optimize conditions for priority
endemic fish species present. The Environmental Flow
Release strategy will be separately consolidated and
documented as part of the overall project ESMP.
Moreover, it should be integrated (and supported)
within the wider Integrated Water Resources

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Apply?
Performance Standards Explanation (Optional)
(Yes/No/TBD)
Management Plan for the Sanaga basin that is being
developed with the support of the World Bank and
AFD.
There are no indigenous peoples on project sites, and
PS 7: Indigenous Peoples No this PS is not applied in the case of this project.

As part of the 2011 ESIA, cultural heritage sites were

PS 8: Cultural Heritage
Project on International Waterways OP/BP
7.50
Projects in Disputed Areas OP/BP 7.60
identified in 15 of the 20 villages surveyed. Several
sites are related to the Sanaga River, and others are
localized in the Project study area (cemetery, forest
sites, sacred trees, etc.). NHPC has developed an
Archaeology Mitigation Plan. NHPC will hire a team of
archeologists before earthworks commence who will
be stationed on site and will be responsible for the
implementation of the plan. EPC contractors are
Yes
contractually required to develop a chance find
procedure as part of their integrated management
system and to communicate NHPC, at least 15 days in
advance, the perimeter of each new area to be
stripped as to allow archeologists to evaluate the risk
of chance finds and put in place the necessary
procedures. NHPC will sign a Memorandum of
Understanding with the Ministry of Culture as
suggested in the Archaeology Management Plan.
No Not applicable.
No Not applicable.

KEY SAFEGUARD POLICY ISSUES AND THEIR MANAGEMENT

A. Summary of Key Safeguard Issues

1. Describe any safeguard issues and impacts associated with the proposed project. Identify and describe any
potential large scale, significant and/or irreversible impacts:

26. The Project may have adverse and irreversible environmental impacts, including: (i) the loss of natural habitat due
to flooding and infrastructure footprint; (ii) predictable environmental, human, health and occupational safety risks
associated with the laterite quarry, construction and operation of facilities; (iii) the risk of reducing the viability of a
distinct population of Leddermaniella and fish species (iv) encroachment into the Mbam Minkom - Kala Birdlife Important
Bird Area (IBA/KBA); (v) loss of access to the river impacts, which negatively affects fishermen and fish traders and (vi)
spread of terrestrial invasive flora species.

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27. The project will generate the permanent loss of land and fishing grounds for populations in the dam impact area,
transmission line, and NHPC base camp in Batchenga. The dam’s footprint will impact around 1470 persons with a land
take for around 142 ha. The transmission line construction, which runs through 25 villages, will necessitate the acquisition
of 247 ha, where 565 agricultural plots will be affected. During operations, NHPC will establish its base camp in the small
in Batchenga. An area of 19 ha has been selected. It will necessitate a land take of around 19 ha that will impact 207 PAPs.
Some sands miners will also be permanently affected by the loss of mining grounds.

2. Describe any potential indirect and/or long-term impacts due to anticipated future activities in the project
area:

28. Indirect and/or potential long-term impacts due to anticipated future activities are associated with: the incidence
of water-related vector-borne diseases; alteration of genetic mixing of fish stocks upstream and downstream of the
proposed dam. To mitigate these long term impacts, NPHC is planning to: (i) to update the Biodiversity Action Plan (BAP)
and ESMP (operation phase) to include the monitoring of biological and hydrological data (flow/water level) at key
locations downstream of the dam with the support of the Leddermaniella and independent fish experts; (ii) establish an
adaptive environmental flow release (EFR) strategy for Nachtigal that responds to changes in the dewatered section of the
river for Leddermaniella spp. (iii) update ESMP to include the monitoring of incidence of water-related vector-borne
diseases and implement control measures as necessary during construction and operation; (iv) will appoint an
independent fish expert with PS 6 experience for at least 3 years to (i) assess the need and (if applicable) evaluate if the
proposed the effectiveness of a catch-and-release program is sufficient to in maintaining the long-term genetic mixing of
fish stocks upstream and downstream of the proposed dam and maintain migratory fish populations. The independent
expert shall also; (ii) provide ongoing advice on the Biodiversity Action Plan-Fish; and (iii) monitoring of Net Gain for the
critical habitat fish species.

29. The RAP and GM processes have identified PAPs with vulnerabilities, including disabilities. 71 potentially
vulnerable and 23 vulnerable PAPs were identified in the dam’s footprint and 26 vulnerable PAPs were identified along
the transmission’s line route. Contractors activities would also generate damage to crops and unforeseen new land
acquisition.

3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts.

30. N/A

4. Describe measures taken by the borrower to address safeguard policy issues. Provide an assessment of
borrower capacity to plan and implement the measures described.

31. The Gov. of Cameroon has already taken significant steps to protect its environment through a National Policy on
Environmental Protection and a series of legislative and regulatory texts for environmental protection and nature
conservation (i.e. comprehensive environmental and social legal framework, including the 1996 Environmental Law and its
implementation decrees). In addition, the dam will be built will respect technical specifications and quality standards that
have been already prepared by NPHC. Furthermore, the borrower prepared an ESIA in November 2006, and it was
updated in September 2011 completed by addendum in January 2014. Resettlement Action Plans and Livelihoods
restoration plans were developed to clearly identify affected populations and to propose compensations measures and
livelihood restauration activities. Additional studies include a Vulnerable Assistance Plan, Resettlement Policy Framework

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to set out the process to address damage to crops by contractors and any unforeseen new land acquisition identified,
detailed cumulative impact assessment (CIA) conducted for Lom Pangar HPP and other downstream hydropower projects,
including Nachtigal HPP (2011); the impact of climate change on hydropower in Cameroun concluded that the Lom Pangar
and Nachtigal storage and hydropower projects (2014); Social influx management plan (2015); local capacities and
manpower study and action plan (2015); Ledermaniella population monitoring and conservation trial (2016); etc. specific
guidelines, including Occupational health safety (OHS), Gender Based violence (GBV), GRM, code of conduct and
compliance with Cameroonian Labor Laws requirements will be developed for contractors, subcontractors and owner’s
engineer. All these requirements will be reflected in the Operation Manual of the project.

32. The Project company (NHPC) has very strong capacity and has demonstrated strong commitment to these issues
during the preparation of the Project. NHPC has set a strong Environmental and social Management System (ESMS).
NHPC’s environmental and social team is comprised of five qualified professionals who have been on site since 2014
playing an active role in the identification of the Project’s environmental and social risks and mitigation measures, and
ensuring the implementation of an effective stakeholder engagement strategy and grievance mechanism. The team, with
the support of qualified consultants, has also actively participated in the government-led census of land to be
expropriated to ensure that the resettlement action plans comply with IFC Performance Standards. NHPC’s environmental
and social team will remain on-site for the duration of construction, ensuring continuous engagement with communities.
NHPC will hire five additional professionals to ensure the implementation of the ESMP and the complementary mitigation
action plans (i.e., RAPs, livelihood restoration for sand miners, management plan of migratory influx, cultural heritage
action plan, biodiversity action plan).

33. Even though experience and capacity for designing and implementing environmental and social safeguards
measures have been acquired from the Lom-Pangar dam project, the Government of Cameroon (GoC) has capacity
limitations and might not satisfactorily ensure a thorough safeguards compliance monitoring. The project design also
recognizes these limitations and has included resources for recruiting the dam safety PoE for Nachtigal HPP in the
“HYDROPOWER DEVELOPMENT ON THE SANAGA RIVER TECHNICAL ASSISTANCE PROJECT” to support the GoC in this
matter. In addition, to ensure a proper safeguards compliance monitoring, the Project will contribute to set up different
Divisional Committees in charge of monitoring ESMPs in the Project areas. The costs associated with their operation
(supervision and inspection missions) will be borne by the Project.

5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard
policies, with an emphasis on potentially affected people.

34. To ensure that the project meets WB-IFC’s requirements, NHPC has committed to update its stakeholder
engagement plan developed in 2015-2016. It will be regularly updated to reflect status and ensure continuous and
comprehensive engagement with all affected stakeholders. The updated will have increased focus on: a) Engagement
with neighboring communities regarding construction schedules, employment, and community health and safety; b)
Continued consultations with specific focus groups (fishers, fish vendors, sandminers, women); c) Targeted engagement
with impacted quarry owners and a more systematic engagement with affected sand miners, to inform them of their
entitlements, compensation process and the reconversion support; d) Coordination with nearby land based construction
projects (Yaoundé water supply, Sanaga bridge) which could potentially contribute to social conflict and benefit
opportunities.

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B. Disclosure Requirements (N.B. The sections below appear only if corresponding Performance standard applies)

35. Due diligence has been performed by key stakeholders during project preparation and this resulted in the
development of an Environmental and Social Impact Assessment (ESIA) validated in 2006 (updated 2011), following which
complementary studies were undertaken. The elaboration of these safeguards instruments was done with an extensive
public participation. Approximately, 51 information and consultation meetings were held and benefiting more than 1700
participants.

36. The ESIA has been disclosed by the World Bank on June 26, 2017. Also, based on the above-mentioned
instruments, an Environmental and Social Review Summary (ESRS) and an Environmental and Social Action Plan (ESAP)
have been prepared, and disclosed on IFC’s web site on June 19, 2017. The ESRS and ESAP have also been disclosed in-
country on NHPC’s web site in June 2017.

C. Compliance Monitoring Indicators at the Corporate Level (to be filled in when the ISDS is finalized by the project
decision meeting) (N.B. The sections below appear only if corresponding PS applies)

Performance Standards
Client’s Environment and Social Assessment
Does the project require a stand-alone Environmental and Yes [ X ] No [ ] N/A [ ]
Social Assessment (including EMP) report?
If yes, then did the Regional Environment Unit or Sector Yes [ X ] No [ ] N/A [ ]
Manager (SM) review and approve the EA report?
Client’s Environmental and Social Management System
Has the client developed an appropriately detailed ESMS, and Yes [ X ] No [ ] N/A [ ]
does the client have the technical and organizational capacity
to implement it?
Labor and Working Conditions
Does the client have a written human resources policy available Yes [ X ] No [ ] N/A [ ]
to all employees that describes labor and working conditions?
Biodiversity and Natural Resource Management
If PS 6 is applicable, would the project result in any significant Yes [ X ] No [ ] N/A [ ]
conversion or degradation of critical natural habitats?
If the project would result in significant conversion or Yes [ X ] No [ ] N/A [ ]
degradation of other (non-critical) natural habitats, does the
project include mitigation measures acceptable to the Bank?
If the project entails use of living natural resources, has Yes [ X ] No [ ] N/A [ ]
certification been obtained or a time-bound plan established to
obtain certification?
Physical Cultural Resources
If PS 8 is applicable, does the project design include adequate Yes [ X ] No [ ] N/A [ ]
measures related to physical cultural resources?
Indigenous Peoples
If PS 7 applicable, and have Indigenous Peoples communities Yes [ ] No [ ] N/A [ X ]
been consulted in accordance with requirements of PS 7?

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Have the requirements for Free Prior Informed Consent been Yes [ ] No [ ] N/A [ X ]
met, and is there reasonable evidence of broad community
support by the affected Indigenous Peoples communities?
Involuntary Resettlement
If PS 5 is applicable, have the requirements been complied with Yes [ X ] No [ ] N/A [ ]
by the client?
Pollution Prevention and Efficient Use of Resources
Does the project comply with good international industry Yes [ X ] No [ ] N/A [ ]
practice as presented in the WBG EHSGs or a similar
internationally recognized benchmark?
Is the project designed for energy efficiency and waste Yes [ X ] No [ ] N/A [ ]
minimization?
Community Health and Safety
Has the assessment determined that local communities could Yes [ X ] No [ ] N/A [ ]
face significant adverse impacts in event of an accident or
emergency situation associated with the project?
If so, has an Emergency Preparedness Plan (EPP) been prepared Yes [ ] No [ X ] N/A [ ]
and arrangements been made for public awareness and
training?
Projects on International Waterways
Have the other riparians been notified by the Bank of the Yes [ X ] No [ ] N/A [ ]
project?
Projects in Disputed Areas
Has the memo conveying all pertinent information on the Yes [ ] No [ ] N/A [ X ]
international aspects of the project, including the procedures to
be followed, and the recommendations for dealing with the
issue, been prepared by the Bank?
Disclosure
If Category A or B, has the ESRS been sent to the World Bank's Yes [ X ] No [ ] N/A [ ]
Infoshop?
Have relevant assessment documents prepared by the client Yes [ X ] No [ ] N/A [ ]
been disclosed in-country in a public place in a form and
language that are understandable and accessible to project-
affected groups and local NGOs?
Monitoring and Reporting
Has the client agreed to submit an Annual Monitoring Report to Yes [ X ] No [ ] N/A [ ]
the Bank to report on the management of environmental and
social risks and impacts, and does the Legal Agreement contain
this provision?
Has the client agreed to report at least annually to local Yes [ X ] No [ ] N/A [ ]
affected communities on how the project is performing with
respect to environmental and social risks and impacts of
concern to those communities?

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CONTACT POINT

World Bank
Contact: Stephan Claude Frederic Garnier
Email: sgarnier@worldbank.org

Contact: Patrice Claude Charles Caporossi

pcaporossi@worldbank.org

Borrower/Client/Recipient
Contact: Pierre Edimo
Title: Chairman CTR
Tel: +23722223816
Email: pedimo_2007@yahoo.fr

Implementing Agencies

Contact: Olivier Flambard

Title: Project Manager Nachtigal
Tel: +237690871520
Email: olivier.flambard@nachtigal-hpp.com

FOR MORE INFORMATION CONTACT

The World Bank
1818 H Street, NW
Washington, D.C. 20433
Telephone: (202) 473-1000
Web: http://www.worldbank.org/projects

APPROVAL

Stephan Claude Frederic Garnier, Patrice Claude Charles Caporossi, Nicolas

Task Team Leader(s):
Sans

Approved By

Safeguards Advisor: Maman-Sani Issa April 2, 2018

Practice Manager/Manager: Charles Cormier April 12, 2018

Country Director: Elisabeth Huybens April 22, 2018

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